In Krouse v. Graham (1977) 19 Cal.3d 59, four juror declarations recited that several jurors "'commented'" on their belief that the plaintiffs' attorney would receive one-third of any award, "'considered'" this belief in making their award and "'determined'" the amount of damages by adding $ 30,000 for legal fees. (Id. at pp. 79, 80.) Though conceding that there was room to construe the declarations as reflecting the jurors' mental processes, the court ultimately held that the declarations were admissible, reasoning that an express agreement to include attorney fees in the award would amount to jury misconduct requiring reversal. (Id. at pp. 81-82.)